Trey Mansfield v. City of Murfreesboro
706 F. App'x 231
| 6th Cir. | 2017Background
- Trey Mansfield, a Murfreesboro K-9 officer, sued the City under Title VII and the FLSA claiming he was denied promotion to K-9 Sergeant in retaliation for protected activity (joining a proposed FLSA collective action about mealtime pay, complaining about schedule changes, and participating in an internal sex-discrimination investigation).
- Major Hudgens had a history of making profane and hostile remarks directed at Mansfield; Hudgens submitted interview questions but recused himself from the promotion board.
- The City announced a K-9 "Sergeant" position; eight applicants applied (including Mansfield and Sergeant Wood, who was already a Sergeant in another unit).
- A seven-member interview board ranked candidates and computed point scores: Wood ranked first overall and was ultimately selected; Mansfield ranked fourth.
- Mansfield alleged the process was a sham and that Hudgens and others hand-picked Wood; the City defended the selection as based on leadership and legitimate non-retaliatory reasons.
- The district court granted summary judgment for the City; the Sixth Circuit majority affirmed, concluding Mansfield had no direct evidence and failed to show pretext under McDonnell Douglas. Judge Moore dissented, arguing sufficient circumstantial evidence created a genuine dispute on pretext.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether court has jurisdiction to hear appeal while consolidated companion case remains pending | Beil precedent: consolidation by court leaves actions separate so appealable | Consolidation might defeat finality | Court: jurisdiction exists under Beil — appealable final order |
| Whether Mansfield has direct evidence of retaliation | Chief Chrisman’s remark that Mansfield was "openly, vocally critical" proves retaliatory motive | Remark requires inferential step; not direct evidence linking protected activity to decision | No direct evidence; inferential leap required |
| Whether Mansfield made a prima facie case of retaliation (causation) | Temporal proximity, pattern of hostile treatment, and other facts support causal link | Selection occurred >1 year after some events; City argues lack of causal nexus | Court assumed prima facie case without deciding, then proceeded to McDonnell Douglas |
| Whether City’s stated reasons for selecting Wood were pretextual | Shifting explanations, overheard comment about "coming up with a good reason," Hudgens’ misconduct and influence show pretext | Wood chosen for leadership; lateral transfer allowed; insufficient proof Hudgens controlled selection or that reasons were false | Court: City articulated legitimate reasons and Mansfield failed to show pretext; summary judgment for City affirmed. Dissent would reverse and remand on pretext question |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for circumstantial discrimination/retaliation claims)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard and allocation of burdens)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (summary judgment—no genuine issue if record could not lead rational jury to find for nonmovant)
- Univ. of Tex. Sw. Med. Ctr. v. Nassar, 570 U.S. 338 (causation standard for retaliation: but-for causation)
- DiCarlo v. Potter, 358 F.3d 408 (definition and scope of direct evidence in discrimination cases)
- Laster v. City of Kalamazoo, 746 F.3d 714 (Title VII retaliation elements)
- Adair v. Charter County of Wayne, 452 F.3d 482 (FLSA retaliation framework)
- Dodd v. Donahoe, 715 F.3d 151 (standard of review for summary judgment in Sixth Circuit)
